Supplemental Notices

  • California Privacy Supplement

    Last updated May 15, 2024

    ‍‍CohenWilson LLP (d.b.a. “DLx Law”) provides you with this California Privacy Supplement (this “Supplement”) as a supplement to the terms of the Privacy Policy (available at https://www.dlxlaw.com/privacy-policy). By visiting the Website (as defined in the Terms and Conditions, available at https://www.dlxlaw.com/terms-and-conditions), you are subject to the Privacy Policy. This Supplement additionally applies to you only if you are a natural person and resident of the U.S. State of California.

    This Supplement provides you with additional information about how DLx Law collects, uses, discloses, and otherwise processes your personal information pursuant to the California Consumer Privacy Act (“CCPA”), as well as what your rights are under the CCPA, in relation to your use of the Website.

    If you have any questions about this Supplement, please contact DLx Law by sending an email to contact@dlxlaw.com.

    IMPORTANT NOTICE: DLx Law reserves the right to change the provisions of this California Privacy Supplement at any time and without providing notice to you. The date of the most recent version of this Supplement will appear at the top of this page. Accordingly, you should visit this Supplement periodically to review and note any changes that might affect you.

    1. What is Personal Information?

    Under the CCPA and as used in this Supplement, “Personal Information” means information that identifies, relates to, or describes a particular consumer or household, or that is reasonably capable of being associated with or could be reasonably linked to, directly or indirectly, a particular consumer or household.

    Personal Information does not include any of the following: (i) publicly available information from government records; (ii) aggregated or anonymized data that is not capable of being associated with you; (iii) information related to job applicants, attorneys, employees, contractors, or other DLx Law personnel; (iv) certain information that DLx Law may process solely on behalf of its clients; and (v) information covered by certain applicable sector-specific state or federal privacy laws, including the U.S. Fair Credit Reporting Act, the U.S. Gramm-Leach-Bliley Act, the U.S. Health Insurance Portability and Accountability Act of 1996, the U.S. Driver’s Privacy Protection Act of 1994, and the California Financial Information Privacy Act.

    2. What Personal Information is Collected?

    ‍DLx Law may collect from you or otherwise gather certain Personal Information about you in connection with your use of the Website. Please review the Privacy Policy to learn more about the information DLx Law collects, including your Personal Information. You can restrict the information collected through the Website by disabling cookies (at https://www.dlxlaw.com/cookie-manager), and by limiting your disclosure of information, such as when submitting a “Get In Touch” form through the Website (available at https://www.dlxlaw.com/get-in-touch); please refer to the Privacy Policy (available at https://www.dlxlaw.com/privacy-policy) for more information. In the last 12 months, DLx Law may have collected the following categories of Personal Information, either directly from you or indirectly collect by way of DLx Law’s partners or suppliers or other third parties who you might authorize to share your information with DLx Law:

    • Individual Identifiers. Names, street addresses, email addresses, and other similar information.‍
    • California Customer Records. Records identifying you, such as by your name, personal physical characteristics signature, telephone number, passport or other government identification number, education or employment history, and credit or other financial history.
    • ‍Other Professional Records. Business and employment records or other professional information, such as your current occupation, job title, employer, and industry.
    • ‍Commercial Information. Information about your or your organization’s commercial activities.
    • ‍Other Personal Information. Your Personal Information that may be identified as part of any question, request, offer, solicitation, or other communication you make to DLx Law via the Website, through social media, or any other means of public communication, which may potentially be gathered from public sources.
    • ‍Cookies and Other Network Information. Information generated from your use of the Website (pursuant to your authorized preferences) on browser and internet use, such as analytics data on your Website activity, which DLx Law may be collected from your browser or device through the use of cookies.
    • ‍Geolocation Data. Your general geographic location based on log data, which may be collected from your browser or device.
    • ‍Sensory Information. Notes, recordings (to which you have consented), or other data from phone calls, remote conferences, or virtual meetings, or any audio files, images, or video footage you choose to provide.

    3. How is Personal Information Used?

    DLx Law may use any of the Personal Information identified above (and from any category) as necessary in pursuit of the following professional legal business purposes, subject to and limited by applicable law and attorney ethics rules: (i) providing or managing your access to any Website content, services, or features, if and as applicable; (ii) managing DLx Law’s relationship with you or your company; (iii) communicating with you, such as by email, phone, push notifications, or social media, or via the Website; (iv) operating, evaluating, securing, enhancing, and improving DLx Law’s business, Website services, and any other related content, services, or features; (v) recognizing you and remembering your information when you return to the Website or when you contact us; (vi) curating and managing DLx Law’s professional activities; (vii) debugging the Website’s intended functionality; (viii) informing tests, training, research, analysis, and content and feature development that supports the Website; (ix) preventing, detecting, and responding to system breaches or other security events; (x) defending, protecting, or enforcing DLx Law’s rights under any applicable agreements, terms, or conditions to which you or your organization may have agreed, including any attorney-client agreement for legal services; (xi) complying with legal, administrative, or judicial process and any applicable legal or regulatory requirements; and (xii) fulfilling rights, enforcing obligations, and performing permitted activities within the scope of any applicable agreements, terms, or conditions DLx Law may have with you or your organization, including any attorney-client agreement for legal services.

    4. When is Personal Information Disclosed?

    In the last 12 months, DLx Law has not sold any Personal Information about you but may have disclosed Personal Information of any of the above categories to DLx Law’s partners or suppliers for a professional business purpose. While DLx Law never “sells” your Personal Information, DLx Law may occasionally disclose your Personal Information to certain of its partners or suppliers for business purposes as necessary to (i) assess and improve the Website or DLx Law’s services; or (ii) detect, stop, and report fraudulent activities. For more information on DLx Law’s disclosure practices as applied to information DLx Law obtains in connection with your use of the Website, please refer to the Privacy Policy (available at https://www.dlxlaw.com/privacy-policy).

    5. What Are Your Rights?

    As a California resident, you may be eligible to exercise any of the following rights in relation to the Personal Information that DLx Law collects, subject to certain limitations under applicable law:

    • Your Right to Know. You have the right to request from DLx Law any or all of the following in relation to any Personal Information DLx Law may have collected about you or disclosed in the last 12 months: (i) the specific information or data points DLx Law has collected from or about you; (ii) the categories of Personal Information DLx Law has collected from or about you; (iii) the general sources of the Personal Information DLx Law has collected from or about you; (iv) the categories of Personal Information that DLx Law has disclosed about you to third parties for business purposes, as well as the types of third parties to whom DLx Law disclosed that Personal Information; (v) the categories of your Personal Information that DLx Law has sold (which is none), and the types of third parties to whom DLx Law sold that Personal Information; or (vi) the business purposes for which DLx Law collected and used your Personal Information. To exercise your right to know, please submit a written request to DLx Law by emailing contact@dlxlaw.com with the subject “California Rights Request.” In your email, identify each of the above categories on which you are seeking information. DLx Law will need to verify your identity before it may process your request, such as by requiring you to log into your account or matching sufficient information provided by you with the information maintained in DLx Law’s systems (which may necessitate requesting additional Personal Information from you). DLx Law may in certain circumstances deny your request, particularly if DLx Law is unable to verify your identity.
    • Your Right to Request Deletion. You have the right to request deletion of Personal Information that DLx Law has collected from you, subject to certain exceptions, such as when DLx Law is providing or has provided Services to you or your company and DLx Law is required by law or internal policy to retain your Personal Information. To exercise your right to request deletion, please submit a written request to DLx Law by emailing contact@dlxlaw.com with the subject “California Rights Request.” In your email, please identify what Personal Information you would like DLx Law to delete to the extent possible. DLx Law will need to verify your identity before it may process your request, such as by requiring you to log into your account or matching sufficient information provided by you with the information maintained in DLx Law’s systems (which may necessitate requesting additional Personal Information from you). DLx Law may in certain circumstances deny your request, particularly if DLx Law is unable to verify your identity.
    • Your Right to Opt Out of Information Sales. You have the right to request that DLx Law not sell your Personal Information to third parties, now or in the future. As indicated above, DLx Law does not ever “sell” your Personal Information to any third parties for purposes of the CCPA, and DLx Law’s partners or suppliers who may have access to some Personal Data are generally prohibited from selling this information (other than in anonymized or aggregated form) to third parties. If, as a result of you exercising your right to know, DLx Law identifies third parties or types of third parties to whom DLx Law may have disclosed your Personal Information, then you should direct any requests exercising your right to opt out of information sales directly to those third parties.
    • Your Right to Non-Discrimination. You have the right not to be discriminated against in any way for exercising any of your other rights above.

  • U.S. State Privacy Supplement

    Last updated May 15, 2024

    CohenWilson LLP (d.b.a. “DLx Law”) provides you with this U.S. State Privacy Supplement (this “Supplement”) as a supplement to the terms of the Privacy Policy (available at https://www.dlxlaw.com/privacy-policy). By visiting the Website (as defined in the Terms and Conditions, available at https://www.dlxlaw.com/terms-and-conditions), you are subject to the Privacy Policy. This Supplement additionally applies to you only if you are a natural person and resident of any of the following U.S. jurisdictions: the States of Colorado, Connecticut, or Utah or the Commonwealth of Virginia.

    This Supplement provides you with additional information about the categories of Personal Data (as defined below) DLx Law collects in relation to your use of the Website, as well as the categories of sources from which it is collected, the purpose for processing, and the categories of third parties to whom DLx Law may disclose the Personal Data pursuant to the following legislation (as applicable and subject to the limitations described in Section 8):

    • If you are a Colorado resident, the Colorado Privacy Act (or “CPA”);
    • If you are a Connecticut resident, the Connecticut Data Privacy Act (or “CTDPA”);
    • If you are a Utah resident, the Utah Consumer Privacy Act (or “UCPA”); or
    • If you are a Virginia resident, the Virginia Consumer Data Protection Act (or “VCDPA”).

    DLx Law may not necessarily be a covered business under any of the above state laws and therefore not necessarily required to afford you any rights or privileges with respect to your Personal Data. DLx Law nevertheless maintains this Supplement and observes the practices outlined under these privacy laws as a demonstration of its commitment to the protection of your privacy.

    If you have any questions about this Supplement, please contact DLx Law by sending an email to contact@dlxlaw.com.

    IMPORTANT NOTICE: DLx Law reserves the right to change the provisions of this U.S. State Privacy Supplement at any time and without providing notice to you. The date of the most recent version of this Supplement will appear at the top of this page. Accordingly, you should visit this Supplement periodically to review and note any changes that might affect you.

    1. What is Personal Data?

    Some personal information or data DLx Law collects from you may not be considered “Personal Data” and may not be covered by this Supplement. Accordingly, this Supplement and your privacy rights might not apply to you or all your personal data.

    Under the CPA, CTDPA, UCPA, and VCDPA, and as used in this Supplement, “Personal Data” means information that is linked or reasonably linkable to an identified or identifiable natural person, but it does not include aggregated or “de-identified” data or publicly available information. Personal Data also does not include (i) information related to job applicants, attorneys, employees, contractors, or other DLx Law personnel; (ii) certain information that DLx Law may process solely on behalf of its clients; and (iii) information covered by certain applicable sector-specific state or federal privacy laws, including the U.S. Fair Credit Reporting Act, the U.S. Gramm-Leach-Bliley Act, the U.S. Health Insurance Portability and Accountability Act of 1996, and the U.S. Driver’s Privacy Protection Act of 1994.

    2. What Categories of Personal Data are Collected?

    ‍DLx Law may collect from you or otherwise gather certain Personal Information about you in connection with your use of the Website. Please review the Privacy Policy to learn more about the information DLx Law collects, including your Personal Information. You can restrict the information collected through the Website by disabling cookies (at https://www.dlxlaw.com/cookie-manager), and by limiting your disclosure of information, such as when submitting a “Get In Touch” form through the Website (available at https://www.dlxlaw.com/get-in-touch); please refer to the Privacy Policy (available at https://www.dlxlaw.com/privacy-policy) for more information. In the last 12 months, DLx Law may have collected the following categories of Personal Data, either directly from you or indirectly collect by way of DLx Law’s partners or suppliers or other third parties who you might authorize to share your information with DLx Law:

    • Individual Identifiers. Names, street addresses, email addresses, and other similar information.‍
    • Professional Records. Business and employment records or other professional information, such as your current occupation, job title, employer, and industry.
    • ‍Commercial Information. Information about your or your organization’s commercial activities.
    • Internet and Other Network-Related Information. Information generated from your use of the Website (pursuant to your authorized preferences) on browser and internet use, such as analytics data on your Website activity, which DLx Law may be collected from your browser or device through the use of cookies.
    • ‍Geolocation Data. Your general geographic location based on log data, which may be collected from your browser or device.
    • ‍Sensory Information. Notes, recordings (to which you have consented), or other data from phone calls, remote conferences, or virtual meetings, or any audio files, images, or video footage you choose to provide.
    • Inferential Information. Inferences drawn from any of the above categories of information, such as preferences or other consumer characteristics.

    3. Through What Categories of Sources is Personal Data Collected?

    DLx Law collects Personal Data in each category through the following sources:

    • Individual Identifiers.

      • Directly from you, such as when you visit the Website or via written forms;
      • From your devices;
      • Via social media platforms and other third-party services;
      • Through email or other correspondence with you; or
      • Using cookies and other tracking technologies.

    • Professional Records.

      • Directly from you, such as when you visit the Website or via written forms;
      • Via social media platforms and other third-party services; or
      • Through email or other correspondence with you.

    • ‍Commercial Information.

      • Directly from you, such as when you visit the Website or via written forms;
      • Via social media platforms and other third-party services; or
      • Through email or other correspondence with you.

    • Internet and Other Network-Related Information.

      • Directly from you, such as when you visit the Website;
      • From your devices;
      • Via social media platforms and other third-party services;
      • Through email or other correspondence with you; or
      • Using cookies and other tracking technologies.

    • ‍Geolocation Data.

      • Directly from you;
      • Based on your IP address when using the Website or accessing certain tools;
      • Through business partners and other providers; or
      • Via DLx Law’s recruitment management systems.

    • ‍Sensory Information.

      • From phone calls and video conferences;
      • Via social media platforms and other third-party services;
      • When DLx Law takes or receives a photograph of you; or
      • When you visit DLx Law’s offices or participate in its discussions or events.

    • Inferential Information.

      • Directly from you, such as when you visit the Website or submit written forms to DLx Law;
      • From your devices;
      • Via social media platforms and other third-party services;
      • Through email or other correspondence with you; or
      • Using cookies and other tracking technologies.

    4. For What Purposes is Personal Data Processed?

    DLx Law may use any of the Personal Data identified above (and from any category) as necessary in pursuit of the following professional legal business purposes, subject to and limited by applicable law and attorney’s ethics rules: (i) providing or managing your access to any Website content, services, or features, if and as applicable; (ii) managing DLx Law’s relationship with you or your company; (iii) communicating with you, such as by email, phone, push notifications, or social media, or via the Website; (iv) operating, evaluating, securing, enhancing, and improving DLx Law’s business, Website services, and any other related content, services, or features; (v) recognizing you and remembering your information when you return to the Website or when you contact us; (vi) curating and managing DLx Law’s professional activities; (vii) debugging the Website’s intended functionality; (viii) informing tests, training, research, analysis, and content and feature development that supports the Website; (ix) preventing, detecting, and responding to system breaches or other security events; (x) defending, protecting, or enforcing DLx Law’s rights under any applicable agreements, terms, or conditions to which you or your organization may have agreed, including any attorney-client agreement for legal services; (xi) complying with legal, administrative, or judicial process and any applicable legal or regulatory requirements; and (xii) fulfilling rights, enforcing obligations, and performing permitted activities within the scope of any applicable agreements, terms, or conditions DLx Law may have with you or your organization, including any attorney-client agreement for legal services.

    5. To What Categories of Third Parties is Personal Data Disclosed?

    DLx Law may occasionally disclose your Personal Data to the following categories of third parties for professional business purposes (and, for more information, please refer to the Privacy Policy, available at https://www.dlxlaw.com/privacy-policy):

    • Individual Identifiers.

      • DLx Law’s affiliates;
      • Organizations providing marketing services;
      • DLx Law’s business partners, service providers, suppliers, and vendors;
      • Legal authorities (as required by law or to protect DLx Law’s rights);
      • Advertising networks and analytics providers;
      • Social media platforms; or
      • Affiliated and nonaffiliated third parties (as may be permitted by law, such as in connection with the sale or restructuring of all or part of DLx Law’s business).

    • Professional Records.

      • DLx Law’s affiliates;
      • Organizations providing marketing services;
      • DLx Law’s business partners, service providers, suppliers, and vendors;
      • Legal authorities (as required by law or to protect DLx Law’s rights);
      • Social media platforms; or
      • Affiliated and nonaffiliated third parties (as may be permitted by law, such as in connection with the sale or restructuring of all or part of DLx Law’s business).

    • ‍Commercial Information.

      • DLx Law’s affiliates;
      • DLx Law’s business partners, service providers, suppliers, and vendors;
      • Legal authorities (as required by law or to protect DLx Law’s rights); or
      • Affiliated and nonaffiliated third parties (as may be permitted by law, such as in connection with the sale or restructuring of all or part of DLx Law’s business).

    • Internet and Other Network-Related Information.

      • DLx Law’s affiliates;
      • Organizations providing marketing services;
      • DLx Law’s business partners, service providers, suppliers, and vendors;
      • Legal authorities (as required by law or to protect DLx Law’s rights);
      • Advertising networks and analytics providers; or
      • Affiliated and nonaffiliated third parties (as may be permitted by law, such as in connection with the sale or restructuring of all or part of DLx Law’s business).

    • ‍Geolocation Data.

      • DLx Law’s affiliates;
      • Organizations providing marketing services;
      • DLx Law’s business partners, service providers, suppliers, and vendors;
      • Legal authorities (as required by law or to protect DLx Law’s rights);
      • Advertising networks and analytics providers; or
      • Affiliated and nonaffiliated third parties (as may be permitted by law, such as in connection with the sale or restructuring of all or part of DLx Law’s business).

    • ‍Sensory Information.

      • DLx Law’s affiliates;
      • Organizations providing marketing services;
      • DLx Law’s business partners, service providers, suppliers, and vendors;
      • Legal authorities (as required by law or to protect DLx Law’s rights);
      • Social media platforms; or
      • Affiliated and nonaffiliated third parties (as may be permitted by law, such as in connection with the sale or restructuring of all or part of DLx Law’s business).

    • Inferential Information.

      • DLx Law’s affiliates;
      • Organizations providing marketing services;
      • DLx Law’s business partners, service providers, suppliers, and vendors;
      • Legal authorities (as required by law or to protect DLx Law’s rights);
      • Social media platforms; or
      • Affiliated and nonaffiliated third parties (as may be permitted by law, such as in connection with the sale or restructuring of all or part of DLx Law’s business).

    6. Is Any Targeted Advertising Used?

    DLx Law may potentially share information from the following categories of Personal Data with third-party cookie, ad-tech providers and others throughout the online advertising ecosystem for purposes of targeted advertising: (i) individual identifiers; (ii) internet and other network-related information; (iii) geolocation data; and (iv) inferential information.

    7. What Are Your Rights?

    As a Colorado, Connecticut, Utah, or Virginia resident, you may be eligible to exercise the following rights (as applicable in your jurisdiction) in relation to the Personal Data that DLx Law collects, subject to certain limitations under applicable law:

    • Rights to Confirm and Access. You may have the right to request that DLx Law confirm, in writing, whether it has processed any of your Personal Data. You also have the right to access the Personal Data DLx Law has collected from or about you.
    • Right to Request Deletion. You may have the right to request deletion of Personal Data that DLx Law has collected from you, subject to certain exceptions, such as when DLx Law is providing or has provided services to you or your organization, or when DLx Law is required by law or internal policy to retain your Personal Data.
    • Right to Correct Inaccuracies. You may have the right to request that DLx Law correct inaccurate Personal Data it has about you, taking into account the nature of the category of Personal Data and the purposes for its processing.
    • Right to Opt Out of Processing for Targeted Advertising. You may have the right to opt out of the processing of your Personal Data for purposes of targeted advertising.
    • Right to Opt Out of Data Sales. You may have the right to request that DLx Law not sell your Personal Data to third parties, now or in the future. As indicated above, DLx Law does not ever “sell” your Personal Data to any third parties for purposes of the CPA, CTDPA, UCPA, or VCDPA, and DLx Law’s partners or suppliers who may have access to some Personal Data are generally prohibited from selling this information (other than in anonymized or aggregated form) to third parties.
    • Right to Opt Out of Profiling. You may have the right to opt out of the processing of your Personal Data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
    • Right to Obtain a Copy of Your Personal Data. You may have the right to obtain a copy of your Personal Data that you previously provided to DLx Law.
    • Right to Non-Discrimination. You have the right not to be discriminated against in any way for exercising any of your other rights above.

    8. How Can You Exercise Your Rights?

    As a Colorado, Connecticut, Utah, or Virginia resident, you may be eligible to exercise the above rights (as applicable in your jurisdiction): To exercise your right, please submit a written request to DLx Law by emailing contact@dlxlaw.com with the subject “<insert your state> Rights Request.”

    In your email to DLx Law seeking to exercise your rights, be as specific as possible identifying each of the categories or specific pieces of Personal Data relevant to your request. DLx Law will likely need to verify your identity before it may process your request, such as by requiring you to log into your account or matching sufficient information provided by you with the information maintained in DLx Law’s systems (which may necessitate requesting additional Personal Data from you). DLx Law may in certain circumstances deny your request, particularly if DLx Law is unable to verify your identity. If DLx Law is unable to verify your identity, it will notify you.

    9. What Kind of Response Can You Expect?

    DLx Law will respond to your request via email, delivering our response to the email address you provided when submitting your request. DLx Law aims to promptly authenticate and respond to your requests within 45 days of receipt but may require up to 90 days to respond to your requests. If DLx Law requires additional time beyond the initial 45 days and that time is reasonably necessary, it will notify you within the first 45 days.

    DLx Law does not ordinarily charge a fee for responding to your requests, but it may impose a fee to the extent your request (alone or in combination with other requests you have submitted) are excessive, repetitive, or manifestly unfounded. If DLx Law determines that charging a fee is warranted, DLx Law will provide you with notice, along with an estimate of the associated costs of responding to your request.

    If DLx Law determines it cannot or will not take the action you requested, it will notify you. DLx Law will inform you of our reasons for not taking action and any rights you may have to appeal the decision.

    10. Are There Any Limitations?

    As described above, the CPA, CTDPA, UCPA, or VCDPA may not be fully applicable to some information or data collected from or about you. Therefore, even if you are a Colorado, Connecticut, Utah, or Virginia resident and submit an authenticated request, DLx Law may not be required to comply with your request.

    Information provided in response to a consumer request will be provided free of charge, up to twice annually per consumer. If requests are manifestly unfounded, excessive, or repetitive, DLx Law may charge a reasonable fee to cover the administrative costs of complying with the request or decline to act on the request.

  • Europe Privacy Supplement

    Last updated May 15, 2024

    ‍CohenWilson LLP (d.b.a. “DLx Law”) provides you with this Europe Privacy Supplement (this “Supplement”) as a supplement to the terms of the Privacy Policy (available at https://www.dlxlaw.com/privacy-policy). By visiting the Website (as defined in the Terms and Conditions, available at https://www.dlxlaw.com/terms-and-conditions), you are subject to the Privacy Policy. This Supplement additionally applies to you only if you are an organization or natural person domiciled in the United Kingdom (U.K.), any of its dependencies, or any nation that is part of the European Economic Area.

    This Supplement provides you with additional information about how DLx Law collects, uses, discloses, and otherwise processes your personal information (or “Personal Data,” as defined below) as a resident of the U.K. or the European Economic Area within the scope of the General Data Protection Regulation (“GDPR”) in relation to your use of the Website.

    If you have any questions about this Supplement, please contact DLx Law by sending an email to contact@dlxlaw.com.

    IMPORTANT NOTICE: DLx Law reserves the right to change the provisions of this Europe Privacy Supplement at any time and without providing notice to you. The date of the most recent version of this Supplement will appear at the top of this page. Accordingly, you should visit this Supplement periodically to review and note any changes that might affect you.

    1. What is Personal Data?

    Under the GDPR and as used in these Disclosures, “Personal Data” means information related to an identified or identifiable natural person who is identified or identifiable, directly or indirectly by means of reference to any particular identifier like name, identification number, location data, a web-based identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person. Personal Information does not include any of the following: (i) a company registration number or generic company email address; (ii) aggregated or anonymized data that is not capable of being associated with you; and (iii) certain information that DLx Law, as a “service provider,” may process solely on behalf of its business customers. DLx Law may potentially be responsible under the GDPR as the “controller” of your Personal Data.

    2. What Personal Data is Collected?

    DLx Law may collect from you or otherwise gather certain Personal Data about you in connection with your or your company’s use of the Website. Please review the Privacy Policy to learn more about the information DLx Law collects, including your Personal Data. You can restrict the information collected through the Website by disabling cookies (at https://www.dlxlaw.com/cookie-manager), and by limiting your disclosure of information, such as when submitting a “Get In Touch” form through the Website (available at https://www.dlxlaw.com/get-in-touch); please refer to the Privacy Policy (available at https://www.dlxlaw.com/privacy-policy) for more information. In the last 12 months, DLx Law may have collected the following categories of Personal Data:

    • Individual Identifiers. Names, street addresses, email addresses, and other similar information that DLx Law may directly collect from you or indirectly collect by way of DLx Law’s partners or suppliers or other third parties you authorize to share information with DLx Law.
    • ‍Employment Application or Recruitment Records. Only to the limited extent you have submitted an employment application to DLx Law or participated in DLx Law’s recruitment process, special categories of information under the GDPR, such as your race and ethnic origin, sexual orientation, or biometric data, which is used by DLx Law only with your express consent and only to assist DLx Law with monitoring its commitments to diversity, equity, and inclusion.
    • ‍Professional Records. Business and employment records or other professional information, such as your current occupation, job title, employer, and industry, which DLx Law may directly collect from you or indirectly collect by way of DLx Law’s partners or suppliers or other third parties you authorize to share information with DLx Law.
    • ‍Other Personal Data. Your Personal Data that may be identified as part of service requests to DLx Law or in social media content and other public communications, which DLx Law may gather from public sources, directly collect from you, or indirectly collect by way of DLx Law’s partners or suppliers or other third parties you authorize to share information with DLx Law.
    • ‍Cookies and Other Network Information. Information generated from your use of the Website (pursuant to your authorized preferences) on browser and internet use, such as analytics data on your Website activity, which DLx Law may collect from your browser or device through use of cookies.
    • ‍Geolocation Data. Your general geographic location based on log data, which DLx Law may collect from your browser or device.
    • ‍Sensory Information. Notes, recordings (to which you have consented), or other data from phone calls, remote conferences, or virtual meetings, or any audio files, images, or video footage you choose to provide, any of which DLx Law may directly collect from you.

    ‍3. How is Personal Data Used?

    Under the GDPR, DLx Law may only use your Personal Data if it has a proper reason for using it. DLx Law may use the Personal Information identified above as necessary in pursuit of the following business purposes, subject to and limited by applicable law and attorney ethics rules: (i) providing or managing your access to any Website content, services, or features, if and as applicable; (ii) managing DLx Law’s relationship with you or your company; (iii) communicating with you, such as by email, phone, push notifications, or social media, or via the Website; (iv) operating, evaluating, securing, enhancing, and improving DLx Law’s business, Website services, and any other related content, services, or features; (v) recognizing you and remembering your information when you return to the Website or when you contact us; (vi) curating and managing DLx Law’s professional activities; (vii) debugging the Website’s intended functionality; (viii) informing tests, training, research, analysis, and content and feature development that supports the Website; (ix) preventing, detecting, and responding to system breaches or other security events; (x) defending, protecting, or enforcing DLx Law’s rights under any applicable agreements, terms, or conditions to which you or your organization may have agreed, including any attorney-client agreement for legal services; (xi) complying with legal, administrative, or judicial process and any applicable legal or regulatory requirements; and (xii) fulfilling rights, enforcing obligations, and performing permitted activities within the scope of any applicable agreements, terms, or conditions DLx Law may have with you or your organization, including any attorney-client agreement for legal services.‍

    4. When is Personal Data Disclosed?

    ‍In the last 12 months, DLx Law has not sold any Personal Data about you but may have disclosed Personal Data of any of the above categories to DLx Law’s partners or suppliers for a business purpose. While DLx Law never “sells” your Personal Data, it may occasionally disclose your Personal Data to certain of its partners or suppliers for business purposes as necessary to (i) assess and improve the Website or DLx Law’s services; or (ii) detect, stop, and report fraudulent activities. For more information on DLx Law’s disclosure practices as applied to information DLx Law obtains in connection with your use of the Website, please refer to the Privacy Policy (available at https://www.dlxlaw.com/privacy-policy).

    ‍5. What Are Your Rights?

    ‍As a resident of the U.K. or of the European Economic Area (which, as of the revision date of this Supplement, includes Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, and Sweden), you may be eligible to exercise any of the following rights in relation to the Personal Data that DLx Law collects, subject to certain limitations under applicable law. Please direct all requests to exercise rights under this Supplement to DLx Law in writing by emailing contact@dlxlaw.com with the subject “European Rights Request” and identifying the nation where you are domiciled. In each instance, DLx Law may need to verify your identity before it may process your request, such as by requiring you to log into your account or matching sufficient information provided by you with the information maintained in DLx Law’s systems (which may necessitate requesting additional Personal Information from you). DLx Law may in certain circumstances deny your request, particularly if DLx Law is unable to verify your identity.

    • Your Right to Access. You have the right to request from DLx Law copies of any and all of your Personal Data that DLx Law has in its position, including the specific information or data points DLx Law has collected from or about you and the business or commercial purposes for which DLx Law collected and used your Personal Data or, though not applicable, sold your Personal Data. To exercise your right to access, please identify in your request to DLx Law any specific categories of information (as listed above, in Section 2) that you want to know about.
    • Your Right to Rectification. You have the right to require DLx Law to correct any mistakes or discrepancies in your Personal Data held by DLx Law. To exercise your right to rectification, when possible, please update your Personal Data at the source of that information, such as through the Website or applicable customer platform application. To exercise your right to rectification, please identify in your request to DLx Law the specific pieces of Personal Data you wish to correct and their corresponding corrections.
    • ‍Your Right to be Forgotten. In some circumstances, you may have the right to request deletion or restrict processing of Personal Data that DLx Law has collected from you, such as if certain information is inaccurate or incomplete or is otherwise not used in accordance with or as permitted under applicable law or regulation. Your right to be forgotten may be unavailable to you if DLx Law is providing or has provided legal services to you or your company and Dlx Law must retain your Personal Information to be able to provide you with adequate client services or where it may otherwise be required to do so by law. To exercise your right to be forgotten, please identify in your request to DLx Law what Personal Data you would like DLx Law to delete or restrict processing and why the GDPR affords you the right in relation to the identified Personal Data for DLx Law’s particular use.
    • Your Right to Data Portability. You have the right to request that DLx Law provide you with your Personal Data in a reasonably establishable format that allows you to more easily reuse your information in another context, and to transmit this data to another data controller of your choice. To exercise your right to be forgotten, please identify in your request to DLx Law what Personal Data and in what format you would like DLx Law to export and to whom, whether you or another data controller, you would like it to be exported.
    • Your Right to Object. You have the right to object to DLx Law processing your Personal Data for purposes of communicating with you or profiling you or your visits to the Website. In certain other, limited circumstances, you have the right to object to DLx Law’s continued processing of your Personal Data as part of processes carried out by DLx Law pursuant to its legitimate business purposes or commercial interests. To exercise your right to object, please identify in your request to DLx Law what processing of Personal Data you would like DLx Law to discontinue. As part of your request, you should also articulate why the GDPR affords you the right in relation to the identified Personal Data for DLx Law’s particular use.
    • Your Right to Opt Out of Automated Decision Making. You have the right to not be subject to a decision based solely on automated individual processing, including profiling, if it produces legal effects concerning you or significantly and directly affecting you. DLx Law does not, however, base any kind of determinations in relation to persons in the U.K. or European Economic Area solely on automated decision-making processes with any legal effect.

    ‍6. How to File a GDPR Complaint?

    While DLx Law hopes to resolve any questions, concerns, or requests to exercise rights concerning its collection and use of your Personal Data (please email contact@dlxlaw.com), the GDPR affords you the right to file a complaint with a supervisory authority of competent jurisdiction in the particular nation where you work or reside, or where any alleged infringement of your rights under the GDPR occurred.

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Amil Malik

Amil assists with various client matters in connection with digital assets and the adoption of blockchain technology, including general corporate law, securities law, and financial services regulation. She joined DLx Law after receiving her J.D. from the George Washington University School of Law, where much of her studies focused on national security and cybersecurity law.

Amil received her B.B.A./B.A. with high honors from the University of Texas at Austin. Between university and law school, Amil worked as a mergers and acquisitions analyst in New York, where she performed financial valuations and analysis as part of advisory services provided to sell-side and buy-side clients across media, consumer, technology, shipping, and financial technology industries. Amil is licensed to practice law in the District of Columbia.

Tom Momberg

+17186645458 tom.momberg@dlxlaw.com

Tom advises clients in an array of matters related to blockchain technology, decentralized finance, banking and payments systems, financial products, and financial technology applications. He joined DLx Law as an attorney after working as in-house counsel for a payments and banking software service provider, advising on various legal and regulatory matters, operations, risk, customer due diligence, and corporate best practices.

Tom received his J.D. from George Mason University Law School in Virginia and his B.A. from the University of Wisconsin-Milwaukee. Tom is a former journalist, and, while in law school, he interned for DLx Law and served as a law clerk for several federal institutions in Washington, D.C., including the CFTC, FCC, and House Judiciary Committee. Tom is admitted to practice law in the District of Columbia and the State of Oregon.

Sarah Chen

+19296345691 sarah.chen@dlxlaw.com

Sarah advises clients in all matters related to the adoption of blockchain technology, including general corporate, venture financing, securities laws and financial regulatory. Prior to joining DLx Law, Sarah was a senior associate in the M&A group of an international law firm headquartered in New York City, advising public companies and private equity firms on mergers, acquisitions, and other corporate transactions.

Sarah received her B.A. from New York University, magna cum laude, and her J.D. from Columbia Law School where she was a James Kent Scholar. During law school, Sarah also served as a judicial extern to the Hon. Debra Ann Livingston of the U.S. Court of Appeals for the Second Circuit. Sarah is licensed to practice law in the State of New York.

Gregory Strong

+3027665535 greg.strong@dlxlaw.com

Greg focuses on advising entities regarding legal issues associated with the adoption of blockchain technology. Prior to joining DLx Law, Greg was a Deputy Attorney General in the Delaware Department of Justice. He served as the Director of the Investor Protection Unit for three years and was responsible for administering and enforcing the provisions of the Delaware Securities Act. Prior to his appointment as Director of the Investor Protection Unit, Greg was the Director of the Consumer Protection Unit for three years.

Greg has successfully represented the State of Delaware in many complex civil enforcement matters alleging violations of Delaware investor and consumer protection statutes and has extensive litigation experience. Greg graduated from Lehigh University with a B.S. in Finance and received his J.D./M.B.A. from Temple University.

Angela Angelovska-Wilson

+12023651448 angela@dlxlaw.com

Angela is an early distributed ledger technology adopter and a leading authority in the evolving global legal and regulatory landscape surrounding distributed ledger technology and smart contracts. Prior to co-founding DLx Law, Angela served as the Chief Legal & Compliance Officer of Digital Asset and was part of the founding team.

Prior to joining Digital Asset, Angela was a partner at Reed Smith where she regularly advised clients on the implementation of new technologies to finance and the complex regulatory schemes involved in the development, creation, marketing, sale and servicing of various financial services and products. Before Reed Smith, Angela spent most of her career in various roles at Latham & Watkins, where she was recognized by The Legal 500 US among the top finance attorneys in the U.S.

Angela has a deep understanding of the Fin-Tech industry and in particular the distributed ledger industry, having been involved in a number of startups in various roles, as an employee, entrepreneur and advisor. In addition to DLx Law, Angela is also co-founder of Sila Inc., an innovative technology company.